BROOKEY & COMPANY PRIVACY POLICY

Last Updated: March 3, 2026

1. Introduction

Protecting your private information is a priority. This Privacy Policy applies to www.brookeyco.com (the “Site”) and Brookey & Company, Inc. (“Brookey & Company,” “we,” “us,” “our”). The Site is a consulting services website. By using the Site, you consent to the data practices described in this Privacy Policy.

2. Personal Information We Collect

We collect information in three ways: (a) information you provide, (b) information collected automatically, and (c) information from service providers that help operate the Site.

2.1 Information You Voluntarily Provide

When you submit information through our contact form or otherwise communicate with us, we may collect:

  • First and last name

  • Email address

  • Phone number

  • Employer or organization

  • Any other information you choose to provide in your message

We do not collect personal information unless you voluntarily provide it.

2.2 Contact Form Data Retention

Brookey & Company does not store or retain personal data submitted through the contact form beyond the time reasonably required to respond to the inquiry, comply with our legal obligations, and maintain customary business records.

3. How We Use Personal Information

We use personal information for the following business purposes:

  • To respond to inquiries and communicate with you about requested information or services

  • To operate, maintain, and improve the Site

  • To understand Site usage and improve content and performance

  • To protect the Site, our business, and users, including fraud and abuse prevention

  • To comply with legal obligations and enforce our rights

We do not use your contact form submission to make automated decisions that produce legal or similarly significant effects.

4. Disclosure of Information to Third Parties

Brookey & Company does not sell, rent, or lease customer lists to third parties.

We may share information with trusted service providers that help us operate the Site and deliver services, such as hosting, analytics, video delivery, and security. These providers are permitted to process personal information only to perform services for Brookey & Company and are required to protect it consistent with their obligations to us.

We may also disclose personal information if required to do so by law or if we believe in good faith that disclosure is necessary to:

  • Comply with legal process

  • Protect and defend the rights or property of Brookey & Company

  • Protect the personal safety of users or the public

  • Investigate and help prevent security incidents, fraud, or abuse

5. Automatically Collected Information

Information about your device and browsing activity may be collected automatically when you visit the Site, including:

  • IP address

  • Browser type and settings

  • Device characteristics

  • Operating system

  • Referring URLs

  • Pages viewed, click paths, and access times

  • Approximate location inferred from IP address

This information is used to operate the Site, maintain quality and security, and produce aggregated analytics.

6. Analytics and Embedded Media

We use third parties to support Site operations and measurement. These providers may process limited personal data such as IP address, page views, click paths, and browser characteristics in accordance with their privacy policies and applicable law.

Current providers may include:

  • Squarespace (website hosting and analytics)

  • Google Analytics (GA4) (aggregated traffic measurement and performance insights)

  • Microsoft Clarity (behavioral analytics such as session replays, click and scroll behavior)

  • Vimeo (video streaming and playback optimization)

When these tools are enabled, they may use cookies, pixels, tags, or similar technologies.

7. Cookie Notice

This Cookie Notice is part of this Privacy Policy.

7.1 What Are Cookies

Cookies are small text files downloaded to your computer or device when you visit a website. Cookies help recognize your browser, remember preferences, support essential site functions, and measure site performance.

7.2 Cookies We Use

We may use the following categories of cookies and similar technologies:

  • Strictly Necessary Cookies to operate the Site and enable core functionality

  • Functional Cookies to remember preferences and improve user experience

  • Analytics Cookies to understand how users interact with the Site and to improve performance

We do not intentionally use targeting cookies to deliver targeted advertising based on your browsing activity on this Site.

7.3 How to Control Cookies

You can control cookies through:

  • The Site’s cookie banner and settings (where available)

  • Your browser controls, including blocking or deleting cookies

Blocking or deleting cookies may affect Site functionality. If you delete cookies, settings preferences may be lost.

7.4 Managing Analytics Technologies

You may opt out of certain analytics collection using the following mechanisms, where available:

8. Social Buttons and External Web Services

The Site may include social sharing buttons or embedded services. These third parties may collect information about your activity consistent with their own policies. We do not control third party data practices. Please review the relevant third party privacy policies.

9. California Privacy Disclosures

9.1 California Shine the Light

We do not share personal information with non affiliated third parties for their direct marketing purposes.

9.2 CCPA and CPRA Rights

If you are a California resident, you may have rights to:

  • Know the categories and specific pieces of personal information collected

  • Know the business purpose for collection and disclosure

  • Request deletion of personal information, subject to exceptions

  • Correct inaccurate personal information

  • Opt out of certain “sharing” or “selling” of personal information (we do not sell personal information as those terms are commonly defined under California law)

10. GDPR and International Users

If you are in the European Economic Area, United Kingdom, or Switzerland, you may have rights under applicable data protection laws, including rights to access, correct, delete, restrict processing, object, and data portability, and to lodge a complaint with a supervisory authority.

10.1 Lawful Bases

Where GDPR applies, we process personal data under the following lawful bases, as applicable:

  • Legitimate interests (for example, responding to inquiries, improving the Site, ensuring security)

  • Consent (for example, where required for certain cookies or similar technologies)

  • Compliance with legal obligations

10.2 International Transfers

If personal data is transferred outside your jurisdiction, we use appropriate safeguards as required by law, which may include Standard Contractual Clauses and other recognized mechanisms. Where applicable, vendors may also rely on additional frameworks or certifications depending on their processing role and location.

11. Information Security

We use reasonable administrative, technical, and organizational safeguards designed to protect personal information from unauthorized access, disclosure, alteration, or destruction. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

12. Children’s Privacy and COPPA

The Site is intended for a general audience and is not directed to children under 13. Brookey & Company does not knowingly collect personal information from children under 13.

In accordance with the U.S. Children’s Online Privacy Protection Act (COPPA) (15 U.S.C. §§ 6501–6506) and its implementing regulations (16 C.F.R. Part 312), we do not knowingly collect, use, or disclose personal information from children under 13 without verifiable parental consent. If we become aware that we have inadvertently collected personal information from a child under 13, we will take reasonable steps to delete that information as promptly as practicable.

If you are a parent or guardian and believe your child has provided personal information through the Site, please contact us via our contact form at https://www.brookeyco.com/contact so we can address the request.

13. Email Communications

From time to time, we may contact you via email for communications related to your inquiry and, if you have requested or consented, announcements or promotional information. You may opt out of marketing emails by using the unsubscribe mechanism in the message.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The “Last Updated” date at the top indicates when changes were made. Your continued use of the Site after updates constitutes acceptance of the updated Privacy Policy.

15. Contact

Questions or requests related to this Privacy Policy should be submitted via our contact form:

/contact

© 2014 to 2026 Brookey & Company, Inc. All Rights Reserved.